Code of Federal Regulations: Containing a Codification of Documents of General Applicability and Future Effect as of December 31, 1948, with Ancillaries and IndexDivision of the Federal Register, the National Archives, 1973 Special edition of the Federal Register, containing a codification of documents of general applicability and future effect ... with ancillaries. |
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Common terms and phrases
20 percent 301 applies accumulated earnings acquiring corporation adjusted basis assets common stock complete liquidation controlled corporation date of distribution December 31 depreciation described in section determined distributing corporation distribution or transfer distributor or transferor dividend carryover earnings and profits erty excess fair market value February 28 Federal feror corporation following examples gain or loss graph holders Internal Revenue Code January June 30 liability loss corporation method of accounting operating loss carryovers operating loss deduction outstanding stock ownership paragraph percent in value personal holding company plan of liquidation poration preceding taxable preferred stock provided in section provisions of section purchase pursuant quiring recognized respect sale or exchange section 306 stock section 381 shareholder Statutory provisions stock of Corporation stock or securities subchapter subparagraph subsection taxable income taxable year beginning taxable year ending tion trade or business transaction transferor corporation treated tribution X Corporation
Popular passages
Page 122 - No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.
Page 137 - No gain or loss shall be recognized If a corporation a party to a reorganization exchanges property, in pursuance of the plan of reorganization, solely for stock or securities in another corporation a party to the reorganization.
Page 118 - No gain or loss shall be recognized If property is transferred to a corporation by one or more persons solely In exchange for stock or securities in such corporation, and Immediately after the exchange such person or persons are in control of the corporation...
Page 137 - If the corporation receiving such other property or money does not distribute it in pursuance of the plan of reorganization, the gain, if any, to the corporation shall be recognized, but in an amount not in excess of the sum of such money and the fair market value of such other property so received, which is not so distributed.
Page 131 - ... has the effect of the distribution of a taxable dividend, then there shall be taxed as a dividend to each distributee such an amount of the gain recognized under paragraph (1) as is not in excess of his ratable share of the undistributed earnings and profits of the corporation accumulated after February 28, 1913. The 'remainder, if any, of the gain recognized under paragraph (1) shall be taxed as a gain from the exchange of property.
Page 121 - ... if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money, then the gain, if any, to the recipient shall be recognized, but in an amount not in excess of the sum of such money and the fair market value of such other property.
Page 139 - For purposes of this part, the term "a party to a reorganization" Includes — (1) A corporation resulting from a reorganization, and (2) Both corporations. In the case of a reorganization resulting from the acquisition by one corporation of stock or properties of another. In the case of a reorganization qualifying under...
Page 71 - ... in complete cancellation or redemption of all the stock, and the transfer of all the property under the liquidation occurs within some one calendar month...
Page 116 - For purposes of this subchapter, a distribution shall be treated as in partial liquidation of a corporation if — (1) the distribution is one of a series of distributions in redemption of all of the stock of the corporation pursuant to a plan; or (2) the distribution is not essentially equivalent to a dividend, is in redemption of a part of the stock of the corporation pursuant to a plan...
Page 144 - If an exchange would be within the provisions of subsection (b) (1), (2), (3), or (5) of this section if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money...